SNFs: Compliance, Medicare Billing and RACs

Despite significant delays due to COVID, Phase 3 requirements of the “mega rule” are now in effect and one of the most unique elements for SNFs is the Ethics and Compliance requirement – 483.25. A good primer on the requirement is attached here. I have highlighted some key points relative to this post. SNF Compliance … Read more

Merge/Affiliation in the Cards?

I pay close attention to economic trends and to the health care industry in general, as the same are applicable. One trend I’m watching quite closely is business consolidation and mergers/affiliations. In the general economy, a lot of consolidation is occurring post-pandemic. Restaurants are closing outlets (Red Lobster, Krispy Kreme, Burger King, etc.), retail outlets … Read more

SNF Proposed Rule – 2024

‘Tis the season for CMS to release updated payment and program rules for providers under Medicare. In the past week or so, we’ve seen releases for Hospice and Inpatient Rehab Facilities. A couple of days ago, CMS released the proposed 2024 rules/updates for SNFs (skilled nursing). The fact sheet for the release is available here: … Read more

Hospice Proposed Rule – 2024

Just about a week ago, CMS released their proposed payment rule for hospices, effective for the Federal Fiscal Year of 2024, beginning October 1, 2023. As readers likely know, these proposed rules are more than just payment rates, incorporating certain regulatory requirements that pertain to the program and Medicare participation (for providers). The rules are … Read more

Litigation Risk and Assisted Living Facilities

As I mentioned in the prior two posts, litigation activity is on the increase, post-COVID, and some of the most fertile ground for plaintiff’s counsel is Assisted Living. SNFs are still as targeted but as stays decrease and facilities improve care capability, the trend remains level, for the most part. Where perhaps, Assisted Living and … Read more

Staffing, Compliance, and Litigation Risk

Not sure how many folks caught this brief article in McKnight’s….The article link is just below. https://na01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.mcknights.com%2Fnews%2Fplaintiffs-lawyers-gaining-edge-against-nursing-home-with-staffing-issues%2F%3Futm_source%3Dnewsletter%26utm_medium%3Demail%26utm_campaign%3DNWLTR_MLT_DAILYUPDATE_0329823%26hmEmail%3DIjP1GPaY%252BJ2uvsLxTJ79bVeRWY7ycbnr%26sha256email%3Daa4cb7c695037c31a216b9562788596b6fcd012145d566f31440b6fcd139c8a9&data=05%7C01%7C%7Cbc9c24d5cbe1440a07e908db314a2be7%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C638157966865063653%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=nvzAvsPBAwKo34DvYAWOf%2Fo5C0URgGaP4msv1jIubGk%3D&reserved=0 Post COVID, all of health care faced a seismic shift in staffing levels. COVID caused wide-spread disengagement in a labor force (clinical) already stressed in numbers. Retirements, especially of nurses, exploded. As COVID abated and the economy began … Read more

Follow-Up: Real Impacts of Poor Quality and Lax Compliance

About ten days ago, I wrote a piece regarding the negative impacts providers can expect (and receive) when quality of care and service combined with vigilance on compliance are not primary in and across their organizations.  All too often, I hear companies and organizations that I work with, say they are committed to quality but by deeds, the evidence is … Read more

Home Health Final Rule: Rate Increases plus PDGM

While I was in Philadelphia speaking at LeadingAge’s annual conference, CMS released its 2019 Home Health Final Rule.  As I wrote in an earlier post regarding the proposed rule, the topic of interest was/is a new payment model – PDGM.  As has been the case across the post-acute industry, CMS is advancing case-mix models crafted around … Read more

Site Neutral Payment Update

In early October, I wrote an article regarding CMS 2019 OPPS (outpatient PPS) proposed rule, specifically regarding site neutral payments.  The purpose of the article was to address the site neutrality trend that CMS is on, streamlining payments to reduced location of care disparities for the same care services.  Succinctly, if the care provided is … Read more

Don’t Miss Event: Webinar on Reducing Rehospitalizations

A week from today, I am conducting a webinar on reducing/avoiding unnecessary rehospitalizations.  With SNFs just experiencing the VBP impact (Medicare incentive or reduction) starting October 1, this event is extremely timely.  I’ll cover the health policy and reimbursement implications regarding rehospitalizations plus new QRP and QM updates.  I’ll also touch on PDPM implications.  Some great … Read more